Challenges for CAF II Communities

Network Capacity and Process Transparency

This study raises two challenges for CAF II-eligible rural communities and policymakers: first is whether CAF II-funded networks are adequate to meet the community’s present and future needs; second, the need for greater transparency in how and where and when the networks are built.

Are 10/1 speeds adequate?

CAF II program critics have roundly derided the FCC’s 10 Mbps/1 Mbps requirement as inadequate at a time when the FCC’s own minimum broadband standard is 25 Mbps/3 Mbps and when providers in competitive markets are regularly delivering Gigabit (1,024 Mb) symmetrical service.

Doug Dawson, a nationally recognized telecommunications consultant and president of CCG Consulting, elaborates: xviii

These upgrades will improve broadband in the affected areas, but only by a small amount. Some residents in these areas today can get very slow DSL, under 1 Mbps. There are also numerous WISPs (wireless internet service providers) operating in the area offering speeds under 5 Mbps. And everybody always has the option of satellite broadband, which is universally disliked due to the latency and data caps.

The really bad news for these areas is that this upgrade is going to be in place for a long time. The FCC is probably not going to think about the CAF II areas again until well past the end of the CAF timeline, perhaps not until 2025. By 2025 the average household in the country is going to probably want a 100 Mbps connection if the current broadband growth trends continue.

In response, the FCC has pointed to the fact that the federal broadband standard was 4 Mbps/1 Mbps at the time when the CAF II program was being designed. xix Defenders xx of the program also point out that the limited federal funds available should be used to provide some level of broadband to the largest number of households. xxi

To address concerns about the capability of the technologies used in these CAF II-funded upgrades, Internet service providers often point to new and emerging technologies that can greatly enhance capacity of DSL over copper, such as G.fast, vectoring and pair bonding. In the case of G.fast, however, a review of the online literature indicates that its successful deployment requires so much fiber that it is most suitable for use in urban settings with multiple dwelling units where fiber optic cabling is just outside the building. Even if G.fast and vectoring did work well in the rural settings where CAF II networks are being built, upgrading the networks to incorporate these more advanced technologies would require additional investment on the part of the provider.

Another defense of the 10 Mbps/1 Mbps expansion is that it is good enough, or at least better than nothing. While true that the CAF II-funded upgrades do result in some rural residents getting access to broadband services of at least 25/3, many more residents served by these upgrades will end up with access to speeds much slower than that. In fact, the FCC’s minimal requirements for these networks do not meet the FCC’s own definition of broadband. The 10 Mbps/1 Mbps access requirements also does not satisfy Minnesota broadband goals. Accepting lower speeds for some parts of Minnesota creates second class status for rural.

Lack of Transparency Disadvantages Communities

Another issue with the CAF II program is its lack of transparency: CAF II does not require participating providers to share or report on any specifics in their network plans beyond the total number of households to be served. The program does include some interim milestones, beginning with 40% of the recipients’ statewide build commitment be completed by the end of 2017. xxii (CenturyLink reports it is on track to have completed 60% of its CAF commitments by the end of 2018.) xxiii

Policymakers have asked the FCC to improve transparency of CAF II plans and projects, so far to no effect. xxiv

This puts community leaders of unserved areas in a quandary. CAF II upgrades do not meet the state speed goals, but they are better than what their residents currently can get. But how much better?

In public meetings and statements, CAF II recipients underscore their commitment to offer broadband speeds that meet or exceed the CAF II 10/1 requirements, often emphasizing the faster speeds available only closest to the node.

Nationally, CenturyLink claims that about 70% of the homes in their target areas served to date with CAF II enabled networks have speeds of 20 Mbps or higher.

Here in Minnesota, community leaders and policymakers are evaluating these statements in the absence of an on the ground picture of what’s actually being built.

This lack of clarity about how participating carriers are spending their CAF II funds inhibits planning and informed stewardship of public resources.

Impact of CAF II-funded Networks